Submission to the NIST AI Risk Management Framework

This report gives comments on the Initial Draft of the NIST AI Risk Management Framework (AI RMF). The key recommendations are to put more emphasis on low-probability, high-impact risks, especially catastrophic risks to society; create a new Socio-Technical Characteristic on “Misuse/Abuse”; create a new Guiding Principle on “Alignment with Human Values and Intentions”; recommend organizations set up an internal audit function to continually assess whether their AI RMF implementation has improved their ability to manage AI risks; review and update the AI RMF frequently.

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